WhatsApp Inc. et al v. NSO Group Technologies Limited et al

Filing 1

COMPLAINT against NSO Group Technologies Limited, Q Cyber Technologies Limited ( Filing fee $ 400, receipt number 0971-13834740.). Filed byFacebook Inc., WhatsApp Inc.. (Attachments: #1 Exhibit 1 through 11, #2 Civil Cover Sheet)(LeBlanc, Travis) (Filed on 10/29/2019)

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Case 3:19-cv-07123 Document 1-2 SHEET CIVIL COVER Filed 10/29/19 Page 1 of 1 JS-CAND 44 (Rev. 07/19) The JS-CAND 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provided by local rules of court. This form, approved in its original form by the Judicial Conference of the United States in September 1974, is required for the Clerk of Court to initiate the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.) I. (a) PLAINTIFFS WHATSAPP INC., a Delaware corporation, and FACEBOOK, INC., a Delaware corporation (b) County of Residence of First Listed Plaintiff (EXCEPT IN U.S. PLAINTIFF CASES) DEFENDANTS NSO GROUP TECHNOLOGIES LIMITED and Q CYBER TECHNOLOGIES LIMITED County of Residence of First Listed Defendant ISRAEL (IN U.S. PLAINTIFF CASES ONLY) NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF LAND INVOLVED. (c) Attorneys (Firm Name, Address, and Telephone Number) Cooley LLP, Travis LeBlanc (251097) 101 California Street, 5th floor, San Francisco, CA 94111 415-693-2000 II. BASIS OF JURISDICTION (Place an “X” in One Box Only) Attorneys (If Known) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff and One Box for Defendant) (For Diversity Cases Only) 1 U.S. Government Plaintiff 3 Federal Question (U.S. Government Not a Party) PTF DEF IV. 4 Diversity (Indicate Citizenship of Parties in Item III) 1 1 Citizen of Another State 2 2 Citizen or Subject of a Foreign Country 2 U.S. Government Defendant Citizen of This State 3 3 CONTRACT TORTS PERSONAL INJURY 310 Airplane 315 Airplane Product Liability 320 Assault, Libel & Slander 330 Federal Employers’ Liability 340 Marine 345 Marine Product Liability 350 Motor Vehicle 355 Motor Vehicle Product Liability 360 Other Personal Injury 362 Personal Injury-Medical Malpractice 120 Marine 130 Miller Act 140 Negotiable Instrument 150 Recovery of Overpayment Of Veteran’s Benefits 151 Medicare Act 152 Recovery of Defaulted Student Loans (Excludes Veterans) 153 Recovery of Overpayment of Veteran’s Benefits 160 Stockholders’ Suits 190 Other Contract CIVIL RIGHTS HABEAS CORPUS 441 Voting 463 Alien Detainee 510 Motions to Vacate Sentence 530 General 442 Employment 443 Housing/ Accommodations 210 Land Condemnation 220 Foreclosure FORFEITURE/PENALTY PERSONAL INJURY 365 Personal Injury – Product Liability 367 Health Care/ Pharmaceutical Personal Injury Product Liability 368 Asbestos Personal Injury Product Liability PERSONAL PROPERTY 370 Other Fraud 371 Truth in Lending 380 Other Personal Property Damage 385 Property Damage Product Liability PRISONER PETITIONS 440 Other Civil Rights 195 Contract Product Liability 196 Franchise REAL PROPERTY 230 Rent Lease & Ejectment 445 Amer. w/DisabilitiesEmployment DEF 4 5 5 6 6 446 Amer. w/Disabilities-Other 245 Tort Product Liability 448 Education BANKRUPTCY 422 Appeal 28 USC § 158 423 Withdrawal 28 USC § 157 PROPERTY RIGHTS 400 State Reapportionment 710 Fair Labor Standards Act 720 Labor/Management Relations 820 Copyrights 830 Patent 410 Antitrust 430 Banks and Banking 450 Commerce 460 Deportation 740 Railway Labor Act 751 Family and Medical Leave Act 790 Other Labor Litigation 791 Employee Retirement Income Security Act IMMIGRATION 462 Naturalization Application 465 Other Immigration Actions 835 Patent–Abbreviated New Drug Application 840 Trademark SOCIAL SECURITY ORIGIN (Place an “X” in One Box Only) 1 Original Proceeding 2 Removed from State Court 3 480 Consumer Credit 485 Telephone Consumer Protection Act 490 Cable/Sat TV 850 Securities/Commodities/ Exchange FEDERAL TAX SUITS 890 Other Statutory Actions 891 Agricultural Acts 870 Taxes (U.S. Plaintiff or Defendant) 871 IRS—Third Party 26 USC § 7609 OTHER Remanded from Appellate Court 4 Reinstated or Reopened 470 Racketeer Influenced & Corrupt Organizations 861 HIA (1395ff) 862 Black Lung (923) 863 DIWC/DIWW (405(g)) 864 SSID Title XVI 865 RSI (405(g)) 540 Mandamus & Other 550 Civil Rights 555 Prison Condition 560 Civil Detainee Conditions of Confinement 290 All Other Real Property OTHER STATUTES 375 False Claims Act 376 Qui Tam (31 USC § 3729(a)) 625 Drug Related Seizure of Property 21 USC § 881 690 Other LABOR 535 Death Penalty 240 Torts to Land VI. PTF 4 NATURE OF SUIT (Place an “X” in One Box Only) 110 Insurance V. Incorporated or Principal Place of Business In This State Incorporated and Principal Place of Business In Another State Foreign Nation 5 Transferred from Another District (specify) 6 893 Environmental Matters 895 Freedom of Information Act 896 Arbitration 899 Administrative Procedure Act/Review or Appeal of Agency Decision 950 Constitutionality of State Statutes Multidistrict Litigation–Transfer 8 Multidistrict Litigation - Direct File CAUSE OF Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity): 18 U.S.C. § 1030 ACTION Brief description of cause: Computer Fraud and Abuse Act DEMAND $ CHECK IF THIS IS A CLASS ACTION VII. REQUESTED IN UNDER RULE 23, Fed. R. Civ. P. Permanent Injunction and Damages COMPLAINT: VIII. RELATED CASE(S), JUDGE DOCKET NUMBER IF ANY (See instructions): IX. DIVISIONAL ASSIGNMENT (Civil Local Rule 3-2) (Place an “X” in One Box Only) SAN FRANCISCO/OAKLAND SAN JOSE DATE 10/29/2019 SIGNATURE OF ATTORNEY OF RECORD CHECK YES only if demanded in complaint: JURY DEMAND: Yes No EUREKA-MCKINLEYVILLE /s/ Travis LeBlanc American LegalNet, Inc. www.FormsWorkFlow.com

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